Update nr. 113
Change of Marpol VI legislation in 2022
As of June 17, the International Maritime Organization (IMO) has adopted key mandatory requirements to reduce the carbon intensity of shipping: introducing the Energy Efficiency Existing Ship Index (EEXI) and the Carbon Intensity Indicator (CII).
These two changes to MARPOL Annex VI will come into force on 1 November 2022.
- Introduction of the Energy Efficiency Existing Ship Index (new Regs. 23 and 25):
The Energy Efficiency Existing Ship Index (EEXI) is a technical efficiency measure that applies to existing ships, and that is equivalent to the Energy Efficiency Design Index (EEDI) for new ships. EEXI assesses the energy efficiency of the design and the equipment of the ship.
Applicable vessels are required to show that their calculated energy efficiency index value (‘attained EEXI’) does not exceed the threshold value (‘required EEXI’) set for their ship type.
EEXI applies to vessels over 400 GT of the following ship type:
- Bulk carrier
- Gas carrier
- General cargo ship
- Refrigerated cargo carrier
- Combination carrier
- Ro-ro cargo ship
- Ro-ro passenger ship
- LNG carrier
- Cruise passenger ship having non-conventional propulsion
Vessels must demonstrate compliance by their next scheduled survey – annual, intermediate or renewal – for the International Air Pollution Prevention Certificate (IAPPC) to be issued or endorsed, or the initial survey before the ship enters service for the International Energy Efficiency Certificate (IEEC) to be issued, whichever is the first on or after 1 January 2023.
- Introduction of the Carbon Intensity Indicator (CII) (new Reg. 28):
Applicable vessels (the same ship types as EEXI but 5,000 GT and above and adding cruise ships using conventional propulsion) will also need to demonstrate operational reductions of carbon intensity.
From 1 January 2023, evidence of carbon intensity reduction must be recorded in a new section of the vessel’s Ship Energy Efficiency Management Plan (SEEMP). As of 1 January 2024, vessels will be issued with a Statement of Compliance, covering verified fuel consumption, attained carbon intensity reduction and an annual rating (A to E) based on carbon intensity reduction performance against the required carbon intensity reduction.
Periodic SEEMP verification audits will be introduced to ensure plans are in place to achieve the targets and ensure correction plans are being followed where a vessel is rated E in any given year, or D in three consecutive years. The frequency and specific requirements of these audits is expected to be discussed at MEPC 77 in November 2021, with guidance developed in 2022.
PSC back to normal – update on Concentrated Inspection Campaigns (CICs)
Several serious incidents have initiated CICs from the major port states. The CIC on Stability in General by the Paris and Tokyo MoUs will be carried out from 1 September to 30 November 2021.
The common CIC on Stability in General was developed by the Paris and Tokyo MoUs and scheduled for 2020. Due to the COVID-19 pandemic, it was postponed for one year. The motivation for the CIC on Stability in General is several serious incidents due to incorrect ship loading conditions or missing intact stability documentation on board.
Most probably, the attending Port State Control Officer (PSCO) will evaluate whether the Master and responsible officers are well trained and familiarized with the stability systems and documentation provided on board. We recommend, that during internal audits special attention is given to this subject.
6th Revision of NSI Covid-19 Contingency Plan Published
On June 25th the Netherlands Shipping Inspectorate published the 6th revision of their Covid-19 Contingency Plan. The contingency plan adheres to all vessels that sail under the Dutch flag (including fishing vessels with a length of 75 meters or more).
The plan emphasizes that the existing regime of statutory surveys and certification should be executed whenever possible. Only when multiple attempts to comply with normal standards have failed due to Covid-19 related restrictions, the provisions of the plan may be applied.
Standing out in this 6th revision is that as of now, extended validity of statutory certificates will only be granted after explicit class approval, and when it can be proven that several attempts to comply with normal standards have been made.
Rood Boven Groen advises that it may be prudent to timely inform yourself on the specific possibilities and conditions that the contingency plan imposes on your particular situation, if you consider to make use of its provisions.
The 6th revision of the NSI Covid-19 Contingency Plan may be downloaded here.